Notice to exporters 2024/21: update on Russia sanctions legal services and revocation of legal advisory services general trade licence

10 September 2024

Russian Sanctions legal advisory services general trade licence has been revoked.

The Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2024 came into force on 6 September 2024 and amends the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia Regulations”). In particular, the exception set out in regulation 60DB of the Russia Regulations has been amended to make it clear that the provision of legal advisory services, which may otherwise be restricted by regulation 54D of the Russia Regulations, are permitted on or in connection with compliance with global sanctions, Russian counter-sanctions and global criminal law.

The amendment also clarifies that legal advisory services are permitted in relation to the application of punitive measures, as well as in relation to compliance with UK statutory or regulatory obligations.

The amending legislation can be read at The Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2024 The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2024 (legislation.gov.uk)

As a result of this amendment the Legal Advisory Services General Trade Licence, which was put in place to facilitate licensing of certain legal services, is no longer required. It was revoked on 6 September 2024, at the point at which the amending regulations came into force.

While the Legal Advisory Services General Trade Licence has been revoked, the provisions of Regulation 76 (General trade licences: records) of the Regulations continue to apply to any act carried out under the authority of this licence.

This means that the records required by this Licence must continue to be kept for a period of 4 years beyond the end of the calendar year in which the record was created and the Provider must permit them to be inspected and copied by any person authorised by the Secretary of State or the Commissioners.

Further guidance and support

Guidance on the scope of sanctions against Russia, including the circumstances in which licences can be granted can be found on the Russia sanctions: guidance page.

Kindly supplied by GOV.UK

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